Claims vs Record disc-010
unresolvedsafety Emergency planning: Valar asked for on-site only, cited state-DOE agreements and drills; none found in public
What was said
- Valar Atomics (safety agreement, code of record and Appendix C.3) (2025-10): Asks to tailor DOE's emergency order to "On-site emergency response only" (no off-site planning), justified by the boundary dose and an 800 m distance to the nearest residence.Ward250 Nuclear Safety Design Agreement, No. 100403, Rev 02 (status: Draft), pages 45 and 54 (Valar Atomics, 2025-10)
- Valar Atomics (safety agreement, state and local coordination) (2025-10): "The State of Utah maintains agreements with DOE regarding notification and coordination" for nuclear facilities; promises responder tours, "Table-top exercises", direct notification links and annual coordination meetings with Emery County.Ward250 Nuclear Safety Design Agreement, No. 100403, Rev 02 (status: Draft), pages 20-21 (Valar Atomics, 2025-10)
What the record shows
- No Utah-DOE notification agreement, public emergency plan, record of a table-top exercise or notification arrangement for residents was found in state, county or DOE records as of 29 September 2026 (safe-016, safe-034).Ward250 Nuclear Safety Design Agreement, No. 100403, Rev 02 (status: Draft), pages 20-21 (Valar Atomics, 2025-10)
- The Nuclear Innovation Alliance reads DOE-STD-1271 as allowing equivalents 'Except for Emergency Planning and Cybersecurity'; the standard's general text still lets a contractor request an exemption. Valar's web summary does not list emergency planning among the alternatives it says DOE approved.A Review of Recent DOE Updates to Its Reactor Authorization Process (Nuclear Innovation Alliance)
- Emery County's fire district minutes: the State Fire Marshal's office 'didn't want to touch it' (November 2025); 'State agencies declined to perform plan review and recommended third-party review' (February 2026); the county has no fire inspector; by March the minutes say only that the issue had been addressed with the fire chiefs.Emery County Fire Protection SSD meeting minutes, February 17, 2026 (header misprints the year) (Emery County Fire Protection Special Service District, 2026-02-17)
- Orangeville's minutes record its ambulance available 13% of the time in June 2026.July 9, 2026 City Council Meeting Minutes (Orangeville) (Orangeville City (Utah Public Notice Website), 2026-07-09)
- Uranium Watch and 25 groups told DOE that coverage of the Valar reactor gave no information on emergency response planning or who to contact.Comments regarding DOE categorical exclusion for advanced nuclear reactors, Docket DOE-HQ-2025-0405 (NIRS and co-signers incl. HEAL Utah and Uranium Watch) (Nuclear Information and Resource Service et al., 2026-03-04)
- The safety agreement required equivalency and exemption requests to 'receive DOE approval prior to DSA submittal'. Valar says DOE approved the final DSA on 23 April 2026 (as POWER reported from Valar's posts), so any decision on on-site-only emergency planning was made before then, in records not published; Valar's own list of DOE-approved alternatives does not include it.Ward250 Nuclear Safety Design Agreement, No. 100403, Rev 02 (status: Draft), page 20 (Valar Atomics, 2025-10)
The gap: Valar asked DOE to require only on-site emergency response and told DOE that state-DOE notification agreements and local drills would back it up. No DOE decision on the request, no state-DOE agreement, no emergency plan and no drill record are public. The State Fire Marshal declined to review the reactor building's fire plans. The paper's justification (p.54) calls boundary doses under 0.5 rem well below EPA's Protective Action Guides. EPA's lowest guide is 1 rem, a factor of 2, and the paper does not address EPA's 5 rem child-thyroid guide for potassium iodide, although it names iodine-131 as the main dose contributor.
In plain termsNuclear plants normally plan how to warn and, if needed, move people nearby; Valar's paper calls that 'off-site evacuation planning.' Valar asked DOE to require planning only inside its own site, arguing that even its worst case stays small beyond the fence. It told DOE that Utah already has agreements with DOE for notifying people and that it would run drills with Emery County responders. No such agreement, no emergency plan and no drill record could be found in public records. The state fire marshal's office declined to review the building's fire plans, and in June the local ambulance was available 13% of the time. Plans may exist that simply are not published; only records requests can show it.
Why it matters: If something goes wrong, neighbors and first responders depend on plans that no public record shows exist.
What would settle it: FOIA to DOE Idaho Operations Office for the approved emergency management program and DOE's decision on the on-site-only request; GRAMA to Emery County Emergency Management, the Emery County Fire Protection District and the Sheriff for plans, agreements and exercise records; GRAMA to Utah DEQ and the Division of Emergency Management for any DOE notification agreement.